Practice areas

We have considerable experience in acting on refinancing and restructuring of private equity backed and other groups, including group reorganisations, debt restructuring and formal insolvency procedures.  Our expertise spans the full range of corporate tax implications to which such arrangements may give rise, including transfer pricing and thin capitalisation issues.

Our experience in advising all types of investment funds and management teams on investment transactions equips us to deal with the complex tax issues that restructuring transactions pose.

Corporate groups may refinance their businesses in preparation for a sale or new investor, particularly if trading conditions are difficult. Our expertise enables us to provide bespoke and tax efficient structuring for such transactions.

Similarly, corporate groups may need to refinance external debt, whether to reduce the costs involved in servicing the debt or avoid enforcement on a default. We are well placed to advise on the structuring and implementation of arrangements to help our clients to achieve these objectives.

We have also acted for a number of private equity houses in structuring equity cures in relation to their investee companies. In these transactions, we determine the optimal way of injecting additional capital into the group and the tax consequences of the new capital structure for the shareholders and the investee group.

We also have considerable experience acting for debt funds and investee groups on "loan to own" transactions.  These transactions give rise to significant tax issues for existing and incoming investors, the management team and the investee companies themselves.  We ensure that the various debt transactions which take place (waivers, capitalisations and transfers) do not give rise to any immediate or deferred tax liabilities. We ensure that tax and structuring issues are identified at an early stage and addressed and that the restructuring does not give rise to unexpected tax liabilities for any of the participants.

In addition, we have advised a number of private equity funds and their investee groups on debt buy-back transactions.  These transactions need to be carefully structured, particularly where there is an acquisition discount.

Dealing with management equity in a tax efficient way is a key requirement of any restructuring. We have advised private equity houses on resetting management equity both within and outside wider restructurings.  In these transactions, we have developed a number of innovative ways of realigning the interests of management with the investors.  We have also acted for management teams in relation to these transactions. Having experience of these transactions from both "sides of the fence" is a real benefit.

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